January 3, 2016

FAA Petition for exemption 14 CFR 11.81

Courthan Enterprises, LLC dba Air to Ground Media

9 Florence Court

Palm Coast, FL 32137

Phone: 386.864.3033

Email: Rob.Wood76@gmail.com

Dear Sir/Ma’am:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) and 14 C.F.R. Part 

11, Courthan Enterprises, LLC (“Air to Ground Media”) hereby applies for an exemption from Federal 

Aviation Regulations (“FARs”) identified below, to allow commercial operations of small, unmanned 

aerial vehicles by and through small, unmanned aerial systems (“sUAS”) for collecting residential and 

commercial real estate site survey data, conducting aerial videography and cinematography, mapping, 

and inspection operations.

This exemption is requested in subject to and in conformance with those operations and protocols 

outlined in this Petition and the enclosed DJI Phantom 3 and DJI Inspire 1 User Manuals, which contains

operational guidance and protocols (“sUAS Operator’s Manual”) and any other requirements

established by the FAA pursuant to the FMRA.

Seeking Exemption for:

14 CFR part 21, Subpart H Airworthiness Certificates and 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and 

(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to 

perform aerial data collection.

About the Petitioner:

Air to Ground Media is a company specializing in professional surveys, inspections, mapping, and aerial 

videography and cinematography. Air to Ground Media seeks to provide high quality imaging for a 

variety of commercial, public, and residential uses, including:

• Residential and commercial real estate photography and videography

• Film and documentary videography and cinematography

• Promotional and marketing media

• Site surveys and environmental monitoring

• Construction, development, and real estate surveying and mapping

• Industrial site surveys

Purpose for Exemption:

Very low-level aerial photography and aerial videography for the purpose of marketing and inspections 

that cannot be accomplished safely from traditional aircraft.
Proposed Operations

sUAS’s proposed for use are the DJI Inspire 1 and DJI Phantom 3.

The Operations Manuals describe, in detail, the policies and procedures for Petitioner's proposed sUAS 

operations. To assist the FAA in its safety assessment of Petitioner's proposed sUAS operations, below is 

a summary of operational limitations and conditions, which will ensure an equivalent or higher level of 

safety to operations conducted under current regulatory guidelines:

1. The sUAS will weigh less than 50 pounds.

2. Flights will be operated within line of sight of the Operator.

3. Maximum total flight time for each operational flight will be limited to the amount of time the sUAS 

can be flown and still maintain a reserve battery power of no less than 25%.

4. Flights will be operated at an altitude of no more than 400 feet above ground level ("AGL").

5. Flights will be operated at a safe lateral and vertical distance from and above any inhabited 

structures, buildings, vehicles, vessels, or people not associated with the operation or who have not 

signed a waiver in advance of the operation.

6. The sUAS Pilot with Pilot in Command responsibilities for the flight will be the designated Operator 

("Operator"). The Operator will be an FAA licensed pilot.

7. The sUAS will operate only within a confined area as described in the sUAS Operator’s Manual.

8. A briefing will be conducted in regard to the planned sUAS operations prior to each day's missions. It 

will be mandatory that all personnel who will be performing duties within the boundaries of the safety 

perimeter be present for this briefing.

9. The Operator will have been trained in operations of sUAS generally and received up-to-date 

information on the particular sUAS to be operated as required in the sUAS Operator’s Manual.

10. Written and/or oral permission from the relevant property holders will be obtained.

11. All required permissions and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

12. If the sUAS loses transmission signal, the sUAS will have the capability to return to a pre-determined 

location and land.

13. Contingency plans will be in place to safely terminate flight if there is a loss of transmitter 

communications or a loss of GPS signal.

14. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

Benefit to the Public

Granting Air to Ground Media’s exemption request furthers the public interest. National policy set by 

Congress favors early integration of UAS into the national airspace in controlled, safe working 

environments such as those propose in this petition. In addition, maintaining worksite safety has been a 

priority of state and local governments for decades.

Conducting aerial videography with the sUAS, instead of manned aircraft, will greatly benefit the public 

by drastically reducing the levels of air and noise pollution generated during traditional aerial video 

production flight operations. By using battery power and electric motors, the sUAS produces no air 

pollution, and is the most viable environmentally conscious alternative to piston or turbine powered 

rotorcraft. The sUAS, while reducing the carbon footprint of aerial video productions, also eliminates 
noise pollution as its battery-powered electric motors are barely audible during the takeoff phase, and 

cannot be heard when operating more than 100 feet above ground level.

By using the sUAS to perform aerial videography, the substantial risk to life and property in the air and 

on the ground, which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of aircrew members located 

onboard the aircraft, the minimal size and weight of a sUAS creates less physical potential for collateral 

damage to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct aerial videography.

In addition, granting the exception will help advance the knowledge base for conducting commercial 

UAS operations. This additional data will help the FAA set future rules regarding UAS flight operations, 

maintenance, and crew qualifications. The public also has an interest in reducing the hazards and 

emissions associated with alternate use of helicopters to conduct similar aerial videography operations. 

The UAS in question is very light weight and does not carry any flammable fuel, further reducing the risk 

from any potential accident.

Equivalent Level of Safety

The sUAS to be operated hereunder, DJI Phantom 3 and DJI Inspire 1 multi-rotor rotorcraft, weighs less 

than 55 pounds with payload, carries neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a secured and sterile area. Unlike other civil 

aircraft, the proposed operations will be controlled and monitored by the Operator pursuant to the 

Flight Operations Manual’s requirements.

These safety enhancements, which already apply to civil aircraft operated in connection with existing 

aerial videography operations, provide a greater degree of safety to the Petitioner's employees, 

members of the public, and property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same 

criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its 

size, speed of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load.

Air to Ground Media’s work is done for the purpose of showing structures and is performed generally 

without any people around and never directly over people. Work would be done during daylight hours 

and always in line of sight. As stated earlier the work would be performed at less than 400 feet AGL. 

Federal Registry Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

Air to Ground Media seeks an exemption from the following rules:

14 CFR part 21, Subpart H Airworthiness Certificates and 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and 

(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

and (2), and 91.417(a) and (b). 
Approval of these exemptions allowing commercial operations of small and lightweight unmanned 

aircraft ("sUAS") to conduct aerial videography and cinematography operations will enhance safety by 

reducing risk to Air to Ground Media’s employees, the general public and property owners.

The DJI Phantom 3 and DJI Inspire 1 sUAS’s, weigh less than 55 pounds, with payload, and powered by 

batteries, eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried

on board. The sUAS is transported to the designated survey area set up. It is not flown from an external 

location to the worksite. The sUAS will carry no passengers or crew and, therefore, will not expose them 

to the risks associated with manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety, supporting the grant of the 

exemptions requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight sUASs operate at slow speeds, close to the ground, 

and in a controlled environment. As a result, they are far safer than conventional aerial videography and 

cinematography operations conducted with fixed wing aircraft or helicopters.

Conclusion

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012—size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security—provides more than adequate justification for the grant of the requested 

exemptions to permit Air to Ground Media to operate sUASs in support of its aerial videography and 

cinematography production operations in accordance with the sUASs Operator’s Manuals.

Granting the requested exemption will benefit the public interest as a whole in many ways, including (1) 

significantly improving safety and reducing risk by alleviating human exposure to danger, (2) improving 

aerial videography operations and decreasing operating costs, and (3) providing an environmentally 

conscientious way of producing aerial videography and cinematography operations.

Respectfully Submitted,

Robert J. Wood – Owner

Air to Ground Media